OCTOBER 12, 2019 2019 BY TOM FOX

In today’s edition of Daily Compliance News:

  • What is a recalcitrant (or pissed off) employee? (GoingConcern)
  • Guilty plea in PetroEcuador FCPA case. (WSJ)
  • Do they or don’t they? Deutsche Bank now says it doesn’t have Trump tax returns. (Washington Post)
  • Fraud comes (back) to track and field. (FT)

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds to explore the recent SEC enforcement action against Mylan and its mischaracterization of the drug EpiPen as a generic drug. This mischaracterization cost the federal government millions of dollars and led the SEC to fine Mylan $30MM.

Some of the highlights include:

  • How can one event have multiple risk scenarios?
  • How risks can ripple across an organization?
  • Who oversees risk for a company in a holistic manner?
  • How can internal controls help to break down silos?
  • Where was compliance?
  • Why do internal controls need to cut across silos to provide (at least) internal transparency?

For additional reading see the following:

Matt’s blog post, Mylan’s Lessons on Silos & Risks, on Radical Compliance.

Where does creativity fit into compliance? In more places than you think. Problem-solving, accountability, communication, and connection – they all take creativity. Join Tom Fox and Ronnie Feldman on Creativity and Compliance, part of the Compliance Podcast Network. In this show, we interview Ula Ubani, Chief Ethics & Conduct Officer for BMO Financial Group who is going to discuss the creative integrity and speak up program BMO developed by working with Ronnie Feldman and Learnings and Entertainment.

The program is entitled the BMO-On-The-Street With Actions Matterly a custom man-on-the-street-style integrity and Speak Up communications campaign, where real employees to championed the cause of compliance. It is the fascinating picture of how a traditionally conservative financial institution recognized the value of trying a more entertaining approach to ensure that employees pay attention to this important subject. They were rewarded by being the only Canadian bank to be recognized as a Worlds Most Ethical Company.

Some of the highlights include:

  • What is the BMO-On-The-Street With Actions Matterly?

o It is man-on-street style videos, interviewing employees and getting them to champion the cause

o  It was named after the BMO theme that Words and Actions Matter

o BMO wanted to be able to tackle the tough subjects

  • Why did BMO take this approach?

o We wanted to involve employee

o We wanted it to be fun and interesting because this can be a tough subject to get at.

  • Was BMO worried about using entertainment and humor and how did you handle that?

o We were careful to make sure that we never made fun of the issue. We made the character interesting/quirky allowing employees to be the heroes of the piece.

  • What was it about the campaign that made it such a success?
  • What have been the results, both expected and unexpected?
  • What advice would you give to others thinking about trying something creative like this…what lessons have you learned?


Ronnie Feldman (LinkedIn)
Learnings & Entertainments (LinkedIn)
Ronnie Feldman (Twitter)

Learnings & Entertainments (Website)

60-Second Communication & Awareness Shorts – A variety of short, customizable, quick-hitter “commercials” including songs & jingles, video shorts, newsletter graphics & Gifs, and more. Promote integrity, compliance, the Code, the helpline and the E&C team as helpful advisors and coaches.

Workplace Tonight Show! Micro-learning – a library of 1-10-minute trainings and communications wrapped in the style of a late-night variety show, that explains corporate risk topics and why employees should care.

Custom Live & Digital Programing – We’ll develop programming that fits your culture and balances the seriousness of the subject matter with a more engaging delivery.

OCTOBER 11, 2019 2019 BY TOM FOX

In today’s edition of Daily Compliance News:

  • What is the cause of SFO delays? (WSJ)
  • EU looks to tweak how it compiles dirty money blacklist. (WSJ)
  • Do they or don’t they? Deutsche Bank now says it doesn’t have Trump tax returns. (Washington Post)
  • OECD to propose international corporate tax reform. (FT)